Environmental charging review of impact of noise and NOx landing charges: update 2017

Transcription

1 Environmental Research and Consultancy Department Environmental charging review of impact of noise and NOx landing charges: update 2017 CAP 1576

2 Published by the Civil Aviation Authority, 2017 Civil Aviation Authority, Aviation House, Gatwick Airport South, West Sussex, RH6 0YR. You can copy and use this text but please ensure you always use the most up to date version and use it in context so as not to be misleading, and credit the CAA. Enquiries regarding the content of this publication should be addressed to: Environmental Research and Consultancy Department, CAA House, Kingsway, London, WC2B 6TE First published 2017 The latest version of this document is available in electronic format at where you may also register for notification of amendments. July

3 Contents Contents Contents... 3 Summary... 5 Chapter Introduction... 6 Chapter Legislative drivers and guidance documents: update... 9 Legislative drivers... 9 Guidance documents Previous and current sets of noise categories Footprints by noise category Noise quota system CAEP NOx standards Chapter Details of charging schemes Heathrow Airport Determination of noise category of aircraft Landing charges overview 2001 to Movement and QC limits during the night quota period Fleet analysis by previous noise category Fleet analysis by current noise category Discussion Gatwick Airport Determination of noise category of aircraft Landing and take-off charges overview Differentiation of noise related charges for 2017/ Determination of noise category of aircraft Movement and QC limits during the night quota period Fleet analysis by noise category Discussion Stansted Airport Determination of noise category of aircraft Landing charges overview Movement and QC limits during the night quota period July

4 Contents Fleet by noise category: analysis Discussion Current framework of noise-related charges at non-designated airports Manchester Airport East Midlands Airport Birmingham Airport Non-designated airports: summary Chapter Emissions-related charges Heathrow Airport Gatwick Airport Stansted Airport Chapter Review of previous and current schemes against CAP 1119 recommendations Chapter Discussions and recommendations Noise Division of noise categories Influence of noise-related landing charges in shifting to best in class Night noise Changes introduced in 2017/ Emissions July

5 Summary Summary This review provides an update to our report Environmental charging Review of impact of noise and NOx landing charges (CAP 1119) published in 2013, to highlight to what extent airports have followed CAP 1119 recommendations and used landing charges to incentivise airlines to use quieter aircraft types to improve their noise performance in order to share the benefit of new aircraft technology with local residents. This report presents noise and emissions related charges in the intervening period since publication of CAP 1119, from 2014/15 to 2017/18. Information is presented on how differential environmental charges have been applied at the three airports designated for noise management by the Secretary of State (Gatwick, Heathrow and Stansted) by considering their fleet mix with respect to aircraft noise category. Recommendations are made regarding: Disaggregation of noise charging categories Earlier signalling of future charging levels Night time charging period Separation of noise charges for arrivals and departures Night period charging levels July

6 Introduction Chapter 1 Introduction 1.1 In 2013, we reviewed noise-related and NOx emissions-related landing charging schemes for airports designated by the Secretary of State, namely Heathrow, Gatwick and Stansted airports as well as three nondesignated airports (Manchester, East Midlands and Birmingham airports) for comparison. Our report Environmental charging Review of impact of noise and NOx landing charges (referred henceforth as CAP ) was published in October The main finding of CAP 1119 was that differential environmental landing charges were unlikely to be the main financial driver for using quieter and less polluting aircraft although they do offer some incentives to operate quieter aircraft. We suggested that more appropriate charge differentials and earlier introduction of the higher charges for categories of aircraft that exhibit poor noise and NOx performance relative to emerging standards, could reasonably increase the incentive to shift to best-in-class aircraft. As such, we made seven recommendations to airports which we believe may improve the effectiveness of landing charging schemes. 1.3 This review provides an update to CAP 1119, to highlight where and where not airports have followed our recommendations: a) Noise charging categories should be based on ICAO certification data, namely the margin to Chapter 3, to incentivise best-in-class. b) Noise charging categories should be of equal width, typically 5 EPNdB, or narrower, to ensure adequate differentiation of noise performance. 1 Environmental charging Review of impact of noise and NOx landing charges. CAP 1119.UK Civil Aviation Authority (2013) July

7 Introduction c) The noise charging categories used at a given airport should cover the full range of aircraft in operation at the airport. This range should be reviewed periodically and modified as appropriate. d) Noise charges for operations occurring at night should be greater than those that occur during the day. e) Where noise-related charge differentials occur depending on the time of day of an operation, the scheduled time of the operation should be used as oppose to the actual time. Penalties may be used to disincentivise operations scheduled to occur on the cusp of the night period that regularly fall into the night period. f) There should be a clear distinction between noise-related landing charges and any non-noise-related charges, e.g. demand-related charges. g) Charging schemes should ideally be harmonised across airports within the UK. Aircraft should be treated similarly from one airport to another, even if the charges at each airport are different. 1.4 As a first report on landing charges, CAP 1119 presented an historical background to landing charging, and to noise and emissions related charges in particular, in the context of general airport charges, the impact that it had on both airports and operators, the rationale for the charges and the benefits that were expected from noise and emissions related charges. It presented data from 2001 up to and including 2014, with a particular focus on the latest year (2013/14) and the proposed changes that the main airports were consulting at the time. 1.5 This report will present, in Chapter 2, background information on the main aspects of environmental landing charges that we address in this report, including a description of noise categories, and relevant legislation and guidance documents. In Chapter 3, a landing charges review and an analysis of the fleet by noise category at each designated airport with some derived conclusions is presented, in addition to a brief description on how the non-designated airports have addressed landing charges by July

8 Introduction comparison. Chapter 4 addresses emission charges, and Chapter 5 presents a review of the current and proposed charging schemes against the recommendations we made in CAP Finally, Chapter 6 concludes with a summary of the main issues addressed and a set of final recommendations. 1.6 As an update report to CAP 1119, this revision is pursuant to the same environmental objectives in relation to DfT s Aviation Policy Framework at the designated airports as well as the environmental objectives of CAA s Five Year Strategic Plan 2. 2 Our CAA Five Year Strategic Plan sets out how we propose to contribute to the development of the UK aviation sector over the five years from , what we want to achieve and how we plan to do it. It is available to view at July

9 Legislative drivers and guidance documents: update Chapter 2 Legislative drivers and guidance documents: update 2.1 CAP 1119 presented the legislative and guidance background relevant to landing charges. In this chapter, only a brief reminder is given, highlighting where changes have occurred in respect to legislative drivers, guidance documents, noise category definitions and NOx standards. Legislative drivers 2.2 The legislative drivers regulating airport charges are, as stated previously in CAP 1119, as follows: i. Civil Aviation Act 2006 ii. Airport Charges Directive (2009/12/EC) iii. Airport Charges Regulations 2011 iv. Balanced Approach Directive (2002/30/EC) v. UK Aerodrome Regulations 2.3 The only change since the publication of CAP 1119 is that the European Union (EU) Balanced Approach Regulations entered into force on 16 April 2016 repealing the Balanced Approach Directive (2002/30/EC). The Balanced Approach Regulations 2014 aim to facilitate the achievement of specific noise abatement objectives, and to enable the use of operating restrictions to achieve sustainable development of an airport. 3 Regulation (EU) 598/2014 of the European Parliament and the Council of 16 April 2014 on the establishment of rules and procedures with regards to the introduction of noise-related operating restrictions at Union airports within a Balanced Approach. European Parliament (2014) July

10 Legislative drivers and guidance documents: update Guidance documents 2.4 Guidance on noise-related charges, as presented in CAP 1119, was provided by the International Civil Aviation Organization (ICAO), namely: i. Policies on charges for airports and air navigation services (ICAO, Doc 9082) ii. Airports Economic Manual (ICAO, Doc 9562) iii. Guidance on the Balanced Approach to Aircraft Noise Management (ICAO, Doc 9829) 2.5 No changes occurred since the publication of CAP Previous and current sets of noise categories 2.6 Noise standards for aircraft certification are set by ICAO to ensure that the latest technological advances in the mitigation of aviation noise are transposed into the design and manufacturing of new aircraft. The ICAO noise standards are set out in ICAO Annex 16 to the Convention on Civil Aviation, Environmental Protection, Volume 1: Aircraft Noise. 2.7 Noise certification involves the measurement of noise levels during the take-off and landing phases of operation in a specific and controlled manner. Three measurements are taken: flyover and sideline (lateral) during take-off, and approach during landing. For each measurement point, the measured level is then compared with the maximum allowed level (limit) as specified in ICAO Annex 16. The difference between each measurement and the maximum allowed level constitutes the noise margin for a given airframe/engine configuration at the certificated take-off and landing masses 4. The sum of the noise margin at each of the measurement points is the cumulative margin. 4 The term mass is used here as the ICAO Annex 16 regulations are related to the aeroplane mass measured in kilograms. Although commonly referred to as the aeroplane weight (including in some airports Conditions of Use documentation), technically speaking, weight is the force on an object due to gravity. July

11 Legislative drivers and guidance documents: update 2.8 The Chapter 2 standard was the first noise standard for subsonic jet aircraft in The Chapter 3 standard became applicable in 1977 and introduced new noise limits at each of the three measurement points such that the Chapter 3 limit has a cumulative margin of at least 16 db lower than Chapter 2. The Chapter 4 standard, introduced in 2006, retained the Chapter 3 limits at each measurement point, but requires that a) the limit at any single point is not exceeded, b) the minimum margin at any two points is at least 2 EPNdB, and c) that the cumulative margin is at least 10 EPNdB (effective perceived noise level in decibels) relative to Chapter 3. The latest standard, Chapter 14, agreed in 2013, retains the Chapter 3 limits, but requires at least 1 EPNdB margin at each measurement point and a cumulative margin of at least 17 EPNdB below than the Chapter 3 limit. 2.9 For charging purposes, further subdivisions are made by certain airports based on the ranges of ICAO Annex 16 noise standards to achieve a greater level of refinement in the noise categorisation of aircraft types, such as those set by the Airports Council International (ACI) allocating an Aircraft Noise Rating Index to each aircraft depending on its cumulative margin. For example, the ACI indices are stepped in 5 EPNdB bands. However, rather than use the ACI rating, airports have traditionally assigned each category a name that relates to the cumulative noise margin or to the noise standard to which it is certified 5, i.e. Chapter 3 Base, Chapter 4 High and so on The previous and current sets of noise categories used by airports in the UK are illustrated in Figure 1, where it can be seen that Chapter 3 is subdivided into two subcategories, Chapter 3 High (between 0 and -5 EPNdB cumulative margin relative to Chapter 3 limit) and Chapter 3 Base (between -5 and -10 EPNdB cumulative margin). Currently, 5 At some airports, aircraft do not need to be officially certified to the relevant ICAO Chapter to be eligible for the corresponding noise charge. Instead airlines at some airports are only required to demonstrate the potential to comply with the noise category claimed. For example, an aircraft certified to the Chapter 4 noise standard that has a cumulative noise margin in excess of 17 EPNdB would qualify for the Chapter 14 noise charge. July

12 Legislative drivers and guidance documents: update Chapter 4 is subdivided into Chapter 4 High (-10 to -15 EPNdB), Chapter 4 Base (-15 to -20 EPNdB) and Chapter 4 Minus (< -20 EPNdB) With the introduction of Chapter 14, some airports have proposed revised noise categories, where the previous lowest category (Chapter 4 Minus) is replaced by a suite of Chapter 14 subcategories, namely Chapter 14 High (-17 to -20 EPNdB), Chapter 14 Base (-20 to -23 EPNdB) and Chapter 14 Minus (< -23 EPNdB). The previous range of Chapter 4 Base, between -15 and -20 EPNdB, is narrowed to between -15 and -17 EPNdB in the current set of noise categories. Departing from the allocation of noise categories based on steps of 5 EPNdB, the new subdivisions of the new Chapter 14 standard are differentiated in steps of 3 EPNdB, leaving the Chapter 4 Base category with a width of 2 EPNdB The Chapter 14 standard will come into effect in 2018 (from 31st December 2017 for aircraft with a MTOW of more than 55 tonnes, and 31st December 2020 for aircraft with a MTOW of less than 55 tonnes), and is therefore not applicable at present. However, the current set of noise categories, used by the UK designated airports, is used in this report to illustrate the incentives that are being built into the charging schemes by the airports for airlines to operate quieter fleets. Figure 1: Previous and current sets of noise categories July

13 Legislative drivers and guidance documents: update 2.13 Aligning the categories with the Chapter 14 limit results in categories that are narrower than 5 EPNdB and no longer of equal width across the range of categories. In responding to local community concern, airports have established noise categories, such that they incentivise the adoption of progressively quieter aircraft. This can be achieved by relating the noise categories to cumulative margin alone. Secondly, having adopted noise categories directly linked to noise performance at certification, progress may be monitored and tracked over time. Footprints by noise category 2.14 In order to appreciate the noise benefits associated with quieter noise categories, Figure 2 illustrates the differences in combined arrival and departure noise footprint area given by the 80 db SEL footprint of a passenger twin engine aircraft (A320/B equivalent) with different cumulative margins (given in steps of 5 db). For illustration purposes, an A320 built in 2000 with CFM56-5B4/2 engines has a cumulative margin of db relative to Chapter 3 limits which put it in the Chapter 4 High category. The footprint of this aircraft would correspond to somewhere between the third and the fourth footprint from the top. In contrast, an A320 built in 2014 with V2527-A5 engines, with cumulative margin of db, is Chapter 14 Base and its footprint is similar to the second footprint from the bottom in Figure 2. July

14 Legislative drivers and guidance documents: update Figure 2: SEL 80 db arrival and departure footprint by noise margin of a 75 tonne twin engine aircraft 2.15 The footprints of 4-engine aircraft are larger than 2-engine aircraft, due to their poorer climb performance on departure. However, the proportional differences between the footprints of a 4-engine aircraft are equivalent to the proportional difference of the footprints of the 2-engine aircraft. Noise quota system 2.16 It is widely acknowledged that noise from night-time aircraft operations can cause a greater adverse effect in humans than noise from daytime operations. As such, some noise charging schemes aim at disincentivising night operations. In addition to noise charging schemes, which can vary between day and night, airports may also apply restrictions on the overall numbers (or types) of movements during the night period. Night flying July

15 Legislative drivers and guidance documents: update restrictions at the designated London airports are set by the Department for Transport, using the Quota Count (QC) system The QC is a numeric classification assigned to a specific aircraft (airframe/engine) configuration, calculated from its ICAO noise certification data. It applies to arrival and departure movements separately i.e. a specific aircraft may have a different Quota Count for take-off and for landing The noise levels in the Quota system are classified into bands of 3 EPNdB corresponding to a doubling of noise energy, i.e. an aircraft classified QC0.25 emits half the noise energy than an aircraft classified QC0.5, and so on. The current noise level classifications and corresponding Quota Counts are presented in Table 1. Table 1: Quota count classifications Noise classification (EPNdB) 6 Quota count More than Less than 84 0 (Exempt) 2.19 The QC system is widely used at airports in the UK for banning, restricting or disincentivising movements of aircraft in certain periods of the day The QC system is of particular importance at the three designated airports during most of the night period. The night period covers from to 07.00, while the night quota period covers from to During the night period QC8 and QC16 aircraft are banned from operating. During the night quota period, QC4 aircraft operations cannot be scheduled. 6 Effective Perceived Noise Decibels, a specialised noise unit used for aircraft noise certification tests. Figures based on average of flyover and sideline for departures, and after 9 EPNdB subtraction from approach value. July

16 Legislative drivers and guidance documents: update 2.21 Further limits are placed on the night quota period at the designated airports. Since 1993 the Government has imposed restrictions on the number of movements and the amount of noise energy emitted (expressed as the sum of the quota counts of all aircraft operating during any one season) during the night quota period at Heathrow, Gatwick and Stansted. The limits of movements and quota are placed for summer and winter seasons separately. The restriction applies to whichever criterion is reached first. In other words, the movement limit cannot be surpassed even if the quota has not been exhausted, and vice versa. The movement and quota limits are revised periodically by the Government Airports are also given flexibility to carry-over unused movements or quota from one season to another, or may over-run the movement or quota limit in one season leading to a deduction in the next. Full details of the scheme are set out in a statutory Notice which is published for each summer and winter season in a Supplement to the UK Aeronautical Information Publication (UK AIP) 7. CAEP NOx standards 2.23 As stated in CAP 1119, ICAO standards exist to ensure, in the most part, comprehensive uptake of the new technology by certain dates. The adoption and entry years as well as the NOx limit of each standard are presented in Table 2. Table 2: CAEP NOx standards NOx standard Adoption year Entry year Limit (grnox/kn) CAEP/ CAEP/ CAEP/ CAEP/ CAEP/ July

17 Legislative drivers and guidance documents: update 2.24 The limit is given in grams of NOx per kilo Newton 8 of thrust per engine and is based on the NOx emitted during a standardised landing and takeoff (LTO) cycle with defined thrust settings and times in mode for landing, taxi-in, taxi-out, take-off and climb respectively Unlike for airport noise charges, airport NOx charges are not directly related to NOx standards, however they are based on the standardised ICAO LTO cycle used to calculate NOx emissions, and are applied proportionately using a charge per kilogramme of NOx emitted during the ICAO LTO cycle. No changes have occurred in relation to NOx standards since the publication of CAP A Newton is the force required to accelerate one kilogram of mass at a rate of 1m/s 2. A kilo- Newton (kn) is 1,000 Newtons. July

18 Chapter As mentioned in CAP 1119, environmental charges are unlikely to be the decisive factor upon which airport users (airlines) base their fleet replacement decisions. Under the current charging schemes that we have reviewed, it is difficult to ascertain the true measure of the influence that differential landing charges have in incentivising airlines to shift to quieter aircraft. CAP 1119 exemplified that environmental landing charges make up a small percentage of the total charges met by airlines (typically less than 5%). 3.2 We stated in CAP 1119 that, in order to increase the influence of environmental landing charges in encouraging a shift to quieter aircraft, differentials between noise categories should be increased. However, there is a concern that high environmental landing charges could become an operating restriction if operators are not given enough time to adapt to a new scheme. There are two ways in which an airline can react to a new set of differential charges, namely: Purchasing newer and quieter aircraft; Bringing quieter aircraft from other routes/airports where noise charges are not so stringent. 3.3 Whilst landing charges are unlikely to trigger the purchase of an aircraft, it is expected that operators will have a fleet renewal strategy. Landing charges are more likely to influence decisions to assign the quietest aircraft of an operator s fleet into the airport with the most stringent noise policy. Because airlines will have different levels of scope to assign quieter aircraft to a given airport, environmental charges may have different impacts on individual airlines some may be able to offset or absorb higher charges on a noisier aircraft type against those of a quieter one, whereas those operating a single fleet type will clearly have limited scope to adapt their operations. July

19 3.4 With these notions in mind, this chapter presents an overview of noise and emissions landing charges in the intervening period since publication of CAP 1119 for each study airport. The main changes in the structure of charges, if any, and the current relativity of charges are also addressed. In addition, the aircraft fleet at each designated airport has been analysed for each of the noise categories set out in Chapter 2, in order to determine the progress made in incentivising the use of quieter aircraft. 3.5 Heathrow Airport Limited (HAL) and Gatwick Airport Limited (GAL) carried out consultations on their schemes of charges (implemented in 2017), which are also addressed in this report. 3.6 We give recommendations at the end of each airport section (if applicable) where changes are checked in relation to CAP 1119 recommendations. In addition, Chapter 5 presents a review of the previous and current schemes against CAP 1119 recommendations. Details of charging schemes 3.7 Details of the charging schemes in use at the study airports are presented in this section. In addition, a summary of the main aspects of the charging schemes is given below (Table 3). The changes, relative to the charges given in CAP 1119, are shaded. The charging schemes of the nondesignated airports chosen for comparison have not changed significantly, and therefore the main focus has shifted to the designated airports in this update report. July

20 Table 3: Summary of charging systems at the study airports Runway charge Type Landing Landing and Departure Relative Charges re. Chapter 3 base Relative Charges re. Chapter 4 base Aircraft Weight parameter Noise category parameter(s) Ch2 Heathrow Gatwick Stansted Manchester East Midlands Birmingham MTOW (stepped) ICAO/ACI noise category MTOW (stepped) ICAO/ACI noise category Landing Departure Departure (landing and departure separately for freight) MTOW (stepped) ICAO/ACI noise category & QC Maximum Take Off Weight Authorised (semicontinuous, rate changes at 25t and 120t) ICAO/ACI noise category & QC MTOW (> 5.8t continuous) QC Departure (landing and departure separately for freight aircraft >30T)) MTOW (continuous for passenger aircraft, semicontinuous for cargo aircraft, rate changes at 30t) 300% 170% n/a n/a Ch3 high 150% 100% n/a n/a Ch3 base n/a n/a 100% 100% n/a n/a Ch3 minus 90% n/a n/a n/a Ch4 90% 100% n/a n/a Ch3 & below 389% 200% Ch4 high 111% Ch4 base 100% 100% Ch14 high 78% 60% Ch14 base 56% 50% Ch14 minus 33% 40% n/a n/a n/a n/a n/a Night period (where relevant to landing charges) Night period, local time Night surcharge 01:00-04:30 23:30-05:59 local time (1 Apr to 31 Oct) 2.5 times day charge 12.6 times summer day charge* n/a n/a 23:30-06:00 23:30-06:00 0% 0% 25% (if QC/4) 0% July

21 Heathrow Gatwick Stansted Manchester East Midlands Birmingham Off-peak Night surcharge, Freight (if different to passenger) Off-peak criteria, local time Off-peak reduction Off-peak reduction, Freight (if different to passenger) n/a n/a n/a n/a Shoulder periods (06:00-07:00 & 21:00-23:30): 302% Night period (23:30-06:00): % depending on QC. n/a n/a Winter all day, and Summer 19:00-23:00 for Arrivals and 19:00-22:30 for Departures 67% summer, 100% winter Winter all day only Reduced winter rates. Combinations of QC values and time periods from 05:30-23:00 74% 19% (MTOW>25t) n/a n/a n/a 48% n/a n/a n/a n/a 300% n/a n/a * The night charge is the same in winter and summer. However, the summer day charge is referenced here as there is no winter day charge. July

22 Heathrow Airport Determination of noise category of aircraft 3.8 The methodology used by Heathrow Airport to determine the noise category of an aircraft is based solely on the cumulative margin, relative to Chapter 3 and adhering to the ranges given in Figure 1. The previous scheme of charges included all noise categories available when using a 5 EPNdB category width i.e. two categories within Chapter 3, and three categories in Chapter 4. In the current scheme, the categories are amended to align with the new Chapter 14 standard in the framework of charges. The new category, as shown in Figure 3, is divided into three new subcategories separated in 3 EPNdB steps. This is clear and transparent and broadly in line with CAP 1119 recommendations; however, the categories are narrower than 5 EPNdB and no longer of equal width across the range of categories. Landing charges overview 2001 to This section looks at the past and present framework of landing charges at Heathrow Airport. A summary of the charging system at Heathrow is presented in Table The most significant change in the framework of landing charges at Heathrow Airport since the publication of CAP 1119, has been the decision by Heathrow Airport to increase, from 2017, the percentage of revenue from environmental charges which currently stands at 21% of total airport charges, to 28% of total airport charges 9. Due to the capping of airport charges 10 at the designated airports, the increase in environmental charges is offset by a reduction in per-passenger charges, which fall from 75% to 68% of airport charges. 9 Heathrow Airport, Airport Charges Structural Review, Decision document, Aug The CAA has powers under the Civil Aviation Act 2012 for the economic regulation of Gatwick and Heathrow airports. July

23 Noise-related landing charge ( ) CAP CAP 1119 presented an historical overview of noise-related charges applied to Heathrow Airport landing operations starting in the year 2001/02 and ending in 2013/14. Maintaining the historical trend, Figure 3 shows noise related charges from the period as well as those in the subsequent years up to the present and including changes for the year 2017/18, which includes the new ICAO Chapter 14 standard as the basis for the lowest charge categories. Figure 3: Noise-related landing charge ( ) per noise category Financial year Noise category 3.12 Following the CAP 1119 review, landing charges for the noisiest categories, Chapter 2 and Chapter 3 High, experienced another steep change in the year 2015/16. Landing charges for Chapter 3 Base aircraft July

24 experienced the biggest increase compared to previous years, from 2,959 in 2016/17 to 8,274 in the year 2017/18, a 180% increase Between 2011 and 2016, the proportional landing charge at Heathrow, relative to Chapter 4 Base has remained approximately the same, as presented in Table 4. Table 4: Landing charge relative to Chapter 4 Base (from 2011 to 2016) Noise category Landing charges relative to Chapter 4 Base Chapter 3 Base 200% Chapter 4 High 120% Chapter 4 Base 100% Chapter 4 Minus 60% 3.14 The scheme of charges for 2017/18, relative to Chapter 4 Base, is presented in Table 5. Table 5: Landing charge relative to Chapter 4 Base (2017/18) Noise category Landing charges relative to Chapter 4 Base Chapter 3 389% Chapter 4 High 111% Chapter 4 Base 100% Chapter 14 High 78% Chapter 14 Base 56% Chapter 14 Minus 33% 3.15 Table 5 shows the proportionally high charge that is applied to Chapter 3, as well as the discounts related to Chapter 14 subcategories. Comparing Table 4 and Table 5 shows the move towards greater charge differentials. Movement and QC limits during the night quota period 3.16 The number of movements allowed to operate at Heathrow airport during the night quota period is limited to 5,800; 3,250 in the summer period and 2,550 in the winter period. July

25 3.17 Table 6 and Table 7 present the movement and noise quota limits at Heathrow airport from 2007 to 2016 for summer and 2006/07 to 2016/17 for winter respectively Figure 4 illustrates the values in Tables 6 and 7. In the summer of 2016, the movement usage was at 90.7% and the noise quota usage was at 45.2% (Table 6). Because the movement limit was not reached, HAL was able to carry over movements to the winter period which reflects the 102.4% movement usage in that period (Table 7 and Figure 5). The fact that the winter movements exceed the movement limit by 2.4% does not constitute a breach of the night restrictions, since the London Airport Noise Restrictions Notice permits up to 10% of unused movements from either season to be carried over into the following season (in contrast to Heathrow, Gatwick carries over unused movements from winter to summer). Table 6: Movements and noise quota usage in the summer period at Heathrow Airport from 2007 to 2016 Movements Noise quota Usage Limit % Used Usage Limit % Used Summer ,047 3, % 5, , % Summer ,922 3, % 4, , % Summer ,848 3, % 4, , % Summer ,066 3, % 4, , % Summer ,958 3, % 4, , % Summer ,853 3, % 3, , % Summer ,837 3, % 3, , % Summer ,714 3, % 3, , % Summer ,802 3, % 2, , % Summer ,949 3, % 2, , % July

26 Figure 4: Movement and noise quota usage against the limits at Heathrow Airport in the summer night quota period between 2007 and 2016 Table 7: Movements and noise quota usage in the winter period at Heathrow Airport from 2006/07 to 2016/17 Movements Noise quota Usage Limit % Used Usage Limit % Used Winter 2006/07 2,659 2, % 4, , % Winter 2007/08 2,710 2, % 4, , % Winter 2008/09 2,715 2, % 3, , % Winter 2009/10 2,682 2, % 3, , % Winter 2010/11 2,577 2, % 3, , % Winter 2011/12 2,581 2, % 3, , % Winter 2012/13 2,668 2, % 3, , % Winter 2013/14 2,715 2, % 3, , % Winter 2014/15 2,676 2, % 2, , % Winter 2015/16 2,696 2, % 2, , % Winter 2016/17 2,612 2, % 2, , % Figure 5: Movement and noise quota usage against the limits at Heathrow Airport in the winter night quota period between 2006/07 and 2016/ Table 3 also shows that HAL s noise charge during the night period increases by 2.5 times the charge outside of the night period. However, HAL define the night period for charging purposes as (local July

27 time), in contrast to, for example, GAL s night charging period which is aligned with the Night Quota Period, i.e (local time). In 2016, there were 31 arrivals during the Heathrow night charging period, compared with 5,502 arrivals during the Night Quota Period HAL s noise charging scheme is currently based on actual arrival time and does not take into account departure time. This leads to a situation where an aircraft may arrive on time, but depart late, potentially into the night period, and face no additional charge. In contrast GAL separate noise charges into arrival and departure elements based on actual arrival and departure time. Fleet analysis by previous noise category Chapter 2 and Chapter 3 High 3.21 CAP 1119 stated that since the adoption of the Chapter 4 standard in 2006, 5 years elapsed (until year 2011/12) before charges for the noisier Chapter 3 categories showed a steep increase in differential charge compared to Chapter 4 charges When the high charge was introduced in year 2011/12 for Chapter 2 and Chapter 3 High aircraft, there were not significant numbers of movements by aircraft in those noise categories. Figure 6 shows the proportion of 24h annual landing movements in Heathrow for each noise category in 2010/11 and in 2015/16, where it can be seen that in 2010/11 11 there was a negligible number (3 operations) of movements served by Chapter 3 High aircraft at Heathrow airport (observe that the column of Chapter 3 High in Figure 6 is unnoticeable). Therefore, the highest charges are effectively a back stop to disincentivise the use of aircraft that do not meet current standards of noise performance, rather than an incentive to shift to quieter aircraft. Subsequent changes observed in 2012/13, 2013/14 and 2015/16 for Chapter 3 High aircraft function in the same way. 11 Noise and Track Keeping system data for Heathrow Airport (ANOMS) queried in June July

28 Percent of 24h annual movements CAP 1576 Figure 6: Heathrow Airport movements distribution (%) by current noise category 50% 45% 40% 35% 30% 25% 20% 15% 2010/ /16 10% 5% 0% Chapter 3 High Chapter 3 Base Chapter 4 High Noise Category Chapter 4 Base Chapter 4 Minus Chapter 3 Base 3.23 Likewise, in regard to the higher charges planned for Chapter 3 Base aircraft for the year 2017/18, as Figure 6 shows, the percentage of movements carried out by Chapter 3 aircraft was less than 1% in Because the charge for this category increased after the proportion of movements dropped to less than 1%, it is apparent that the charge increase is aimed at preventing the re-introduction of these aircraft into the airport fleet, i.e. a back-stop, rather than a continued incentive to shift to quieter aircraft. Chapter The proportion of aircraft in each of the Chapter 4 subcategories, as seen in Figure 6, illustrates the intended progression in shifting to best in class whereby the noisiest aircraft have less proportion of the fleet, increasing gradually for each noise category. Fleet analysis by current noise category 3.25 In 2017/18 HAL has introduced Chapter 14 noise categories in the scheme of landing charges. Figure 7 shows the 24h annual movement distribution by the newly adopted set of noise categories at Heathrow Airport, including the new Chapter 14 High, Base and Minus noise July

29 Percent of 24h annual movements CAP 1576 categories. It can be seen that, in 2015/16, 56% of operations are carried out by aircraft complying with the new Chapter 14 noise standard (42% of Heathrow Airport fleet), comprising 9% Chapter 14 High, 37% Chapter 14 Base and 10% Chapter 14 Minus aircraft. The reduction of the Chapter 4 Base width from 5 to 2 EPNdB (from -15 to -20 EPNdB in the previous noise category scheme to -15 to -17 EPNdB in the newly adopted categorisation) has caused the percentage of movements of Chapter 4 Base aircraft to decrease significantly from 35% to 26%, based on 2015/16 and 2010/11 data. Figure 7: Heathrow Airport movements distribution (%) by proposed set of noise categories 40% 35% 30% 25% 20% 15% 10% 2010/ /16 5% 0% Chapter 3 Chapter 4 High Chapter 4 Base Chapter 14 High Noise Categories Chapter 14 Chapter 14 Base Minus Discussion 3.26 HAL has applied differential charging across all noise categories. The highest charges correspond to aircraft of noise categories that serve a marginal number of operations. The steepest charges are an effective back stop to re-introduction and the lower charges an incentive to shift to best in class aircraft, which is the intention behind the implementation of differential charging With the adoption of the Chapter 14 standard, and the replacement of most Chapter 3 aircraft, Chapter 4 becomes the next noise charging category to be addressed for phasing out of operations at the airport. The July

30 Chapter 4 High category accounts for 17% of operations at present whereas Chapter 4 Base aircraft serve 26% of operations HAL recently published its Heathrow 2.0 plan for sustainable growth 12. Although it contains no specific commitment to increase noise landing charges, it signals that HAL will continue to use noise landing charges as an important part of their toolkit in order to meet their targets to reduce the proportion of Chapter 3 and 4 aircraft, and to increase the proportion of Chapter 14 aircraft operating at Heathrow. We welcome the recognition that noise based landing charges can be an effective incentive to enhance noise performance. However, the CAA considers that there is scope to enhance the targets within Heathrow 2.0 to deliver greater noise reduction. For instance, in Heathrow 2.0, the goal for operational aircraft compliance with Chapter 14 is 60% by 2020: in 2015/16, 42% of Heathrow aircraft, operating 56% of movements, were Chapter 14 compliant As mentioned in the introduction to this chapter, airlines can respond in two ways to a new scheme of differential noise charges: purchasing quieter aircraft and/or substitution within their existing fleet elsewhere. In addition, the airport can, at its own discretion, set landing charges in such a manner whereby operators can counterbalance higher charges from their noisier aircraft with those from the quieter aircraft. The latter is the less onerous option but although, on average the fleet at Heathrow Airport has more than 50% of operations served by Chapter 14 aircraft, airlines may not necessarily have enough quieter aircraft in their fleet to counterbalance higher charges for the noisier aircraft We consider that earlier signalling of the introduction of higher charges can provide a more effective and efficient outcome giving operators an increased ability to respond as opposed to the current practice that typically gives less than one-year s notice before charges are introduced. 12 Heathrow 2.0: Our plan for sustainable growth, Heathrow Airport Limited, accessed 01/06/2017. July

31 3.31 Looking retrospectively at the charges applied to Chapter 3 Base aircraft, over the ten years following the adoption of the Chapter 4 noise standard in 2006, Chapter 3 Base aircraft charges were levied at % of the Chapter 4 Base tariff for four years, and then six years being levied at 200% of Chapter 4 tariff. For the year 2017/18, the residual Chapter 3 Base aircraft remaining at Heathrow is levied 389% the tariff of Chapter 4 Base aircraft (see Figure 8). Figure 8: Historical scheme of charges for Chapter 3 Base aircraft at Heathrow Airport 3.32 It is difficult to ascertain to what extent the phasing out of Chapter 3 aircraft is due to the incentive in landing charge differentials or part of the natural cycle of replacing older aircraft with newer models. It is arguable whether the scheme of charges of Chapter 3 base aircraft, as seen in Figure 8, was as effective as it could have been compared to a scenario in which, on year zero (2006/07), the airport, after consultation with stakeholders, signalled a ten-year scheme to remove Chapter 3 Base aircraft with a proposed scheme of differential charges. This sort of initiative would have allowed operators to consider their fleet options well in advance, and, in addition, such a forecast scheme could have provided July

32 a base for stakeholders to discuss its reasonability and its impact. Moreover, it would undoubtedly be beneficial to transparency Therefore, we believe that a forecast, in consultation with stakeholders, setting out the likely rate of increase in charges for Chapter 4 aircraft, assessing the potential ability of operators to reasonably bring best in class from their forecasted fleet, would show the continued efforts that HAL is making to shift Heathrow Airport s fleet to quieter aircraft With regard to night noise charges, as discussed in paragraph 3.19, we recommend that HAL align its night noise charging period with the Night Quota Period, recognising the additional disturbance caused by flights before In addition we recommend that HAL separate noise charges into arrival and departure elements based on actual arrival and departure time. Gatwick Airport Determination of noise category of aircraft 3.35 The methodology followed by Gatwick airport up until 2016/17 to determine the noise category of aircraft was as follows: Chapter 2: Aircraft which are either not certificated or fail to meet the noise certification standards of ICAO Annex 16 Chapter 3. High: Defined set of aircraft that meet the noise certification standards of ICAO Annex 16 Chapter 3 unless the operator can provide satisfactory noise certification data demonstrating that the aircraft noise performance is at least - 5 EPNdB (cumulative) below the ICAO Annex 16 Chapter 3 certification limits. Base: Aircraft which meet the noise certification standards of ICAO Annex 16 Chapter 3 and are not classified as either Chapter 3 High or Chapter 3 Minus. July

33 Minus: Aircraft which meet the Chapter 3 standard and, on both arrival and departure, have a Quota Count 13 (QC) of 0.25, 0.5 or 1, or are exempt from a QC rating Chapter 4: Aircraft which were either put into service on or after 1 January 2006 and meet the noise certification standards of ICAO Annex 16 Chapter 4 or can demonstrate that they meet the noise certification standards of ICAO Annex 16 Chapter From the year 2017/18, GAL grouped all Chapter 3 and below aircraft into a single noise charging category (Chapter 3 and Below), with the Chapter 4 category remaining unchanged. The airport also introduced Chapter 14 High, Base and Minus in its framework of charges. These subcategories are each 3 EPNdB wide and based on the cumulative margin to Chapter 3 exceeding -17, -20 and -23 db respectively. Landing and take-off charges overview 3.37 This section looks at the past and present framework of landing and takeoff charges at Gatwick Airport. In addition, a summary of the charging system at Gatwick Airport is presented in Table Gatwick Airport Limited (GAL) levies a runway charge on both arrival and departure operations. Before the current year (2017/18) the runway charge did not discern between demand and environmental allocations. This was highlighted by CAP 1119, stating that the framework of charges at Gatwick airport was more demand based than noise related, as night operations in winter did not incur a landing charge for aircraft in categories Chapter 3 Base or above, and charges in the off-peak summer season (which includes the sensitive night period) offered a 67% discount relative to summer peak time Consequently, in the year 2015/16, GAL changed its charging framework dividing the off-peak summer period into evening ( ) and night ( ). During the night period, operations were charged at base 13 The Quota Count is a weighting attributed to the arrival or departure of a specified aircraft type by reference to its certificated noise performance, divided into 3 EPNdB bands. July

34 rates, while evening operations were charged at 36% of the base rate. In addition, operations during the winter-night period were charged the same as summer evening operations (at 36% of base charges). This scheme of charges was maintained in the year 2016/17 in terms of proportion, however the absolute value of charges had increased by 10% from 2014/15 to 2016/ In addition, following a consultation and published decision on airport charges 14,15, GAL decided to divide landing and take-off charges into demand-related charges (82% of revenue from aircraft movement charges) and environment-related charges (18% of revenue from aircraft movement charges, divided equally between noise-related charges and emissions-related charges) in 2017/18. With this scheme, GAL is expected to recover 50% of noise charges from movements in the night period in the year 2017/18, despite the fact that in 2016 night movements accounted for just 5% of total movements. For context, aircraft movement charges make up approximately 27% of core services charges, with 65% raised from passenger charges and the remaining 8% from parking charges Another change in the framework of charges at Gatwick Airport has been the introduction of a financial mechanism for Airbus A320 aircraft that emit a high-pitched tone from the airframe. The tone is generated by the aircraft s Fuel Over Pressure Protection (FOPP) system and is apparent only during approach when engine noise is low and the flaps are retracted and landing gear are not lowered. Airbus has developed a modification to eliminate the tone, which also lowers the noise level during approach, which became standard on all A320 aircraft made after The modification is also available for retrofit to existing A320 family aircraft. In /18 Airport Charges Consultation Aircraft Noise Charges-Phase 2 Consultation. Gatwick Airport Ltd (April 2016) /18 Airport Charges Consultation Aircraft Noise Charges-Phase 2 Consultation Decision Advice. Gatwick Airport Ltd (September 2016) /18 Airport Charges Consultation. Charges Overview & Consultation Timetable. Gatwick Airport Ltd (September 2016). July

35 order to incentivise the retrofit, from January 2018, unmodified A320 aircraft will be charged the same as Chapter 3 aircraft in the night period The current framework of charges (2017/18) recognises the new Chapter 14 noise standard, bringing a charging structure with a single Chapter 4 category and Chapter 14 disaggregated into High, Base and Minus categories according to the proposed categories shown in Figure 1. This reflects the noise performance of the current fleet, and the expectation that some of the largest operators at Gatwick are renewing their fleet, principally with the latest versions of the A320 and B737 aircraft As a result of some of these changes, the charges in some noise sensitive periods of the day have increased significantly since the publication of CAP Figure 9 shows a comparison of charges in the period 2014/ /18 for Chapter 4 aircraft (the most common with 82% of the UK-registered fleet, and 88% of total operations at Gatwick in 2015). Among the changes worth noting are: There was no charge for Chapter 4 aircraft to land in the winter night period prior to the 2017/18 charging period where a charge has been introduced (note in Figure 9 that there are no columns for the years 2014/15 to 2016/2017 for the winter night period). In 2015/16, the summer night period had a 200% increase from the previous year. July

36 Charge ( ) CAP 1576 Figure 9: Gatwick Airport evolution of noise and demand related charges per departure movement* for Chapter 4 aircraft at Gatwick Peak Summer Base Summer Off-Peak Summer Summer Night Winter Night Tariff 2014/15 Tariff 2015/16 Tariff 2016/17 Tariff 2017/18 * Charges shown correspond to departures, as peak period charges do not apply to arrivals 3.44 It is also worth noting that with the charging scheme reflecting new categories based on the new Chapter 14 standard, Chapter 4 aircraft movements in 2017 is 33% of that in % of current Chapter 4 aircraft (UK registered) at Gatwick are eligible for Chapter 14 standard charges which is in effect a reduction in the charges relative to the previous year. In addition, the winter day period does not command a noise or demand charge To illustrate this, Figure 10 presents the charges that are applied to Chapter 4 and Chapter 14 aircraft under the scheme of charges for year 2017/18 for the different time periods. For the summer night period, the discounts offered to Chapter 14 aircraft (with charges of 512, 463 and 414 for Chapter 14 High, Chapter 14 Base and Chapter 14 Minus respectively) means that charges for movements in that period are lower than that in the year 2016/17 for the same period, which was 622 for Chapter 4 aircraft. July

37 Figure 10: Comparison between Chapter 4 and Chapter 14 charges for year 2017/18 Differentiation of noise related charges for 2017/ In segregating landing and take-off charges into demand and noise related charges, GAL has considered loudness based on cumulative margin as a proxy for the differentiation of noise related charges. Subsequently, noise categories are given a noise ratio (or multiplier) relative to Chapter 14 Minus based on the difference between the cumulative margin of their lower limits The lower limit for each noise category is the lower threshold of their range, i.e. 0 EPNdB for Chapter 3, -10 EPNdB for Chapter 4, -17 EPNdB for Chapter 14 High, - 20 EPNdB for Chapter 14 Base and -23 EPNdB for Chapter 14 Minus (see Figure 1). The resulting charge relativities per noise category and their value can be seen in Table 8 below. GAL initially proposed to levy night noise movements at ten times the day tariff. In doing so, the proportion of noise charges recovered for day movements would have been 53%, and 47% for night movements respectively. After consultation GAL decided to recover 50% of noise charges from the day period and 50% from the night period. Consequently, the charges during the night period were adjusted resulting in them being more than 12 times the day charge. July

38 Table 8: Gatwick Airport noise-only charge relativities for 2017/18, relative to Chapter 4 Noise categories Day Night % of Chapter 4 Chapter 3 and below % Chapter % Chapter 14 High % Chapter 14 Base % Chapter 14 Minus % 3.48 In order to compare landing and take-off charges at Gatwick Airport between the current segregated framework (demand and noise related) and the previous scheme of charges (which combines noise and demand), Table 9 presents demand charges, and Table 10 shows the charges (demand and noise) applied for different time periods in the new framework of charges for 2017/18. Table 9: Gatwick Airport demand charges for 2017/18 Period Demand Charges Applicability Peak 972 July and August between 05:00-09:00 for departures only Base 648 1st April to 31st October, between 05:00-19:00, except July and August which is from 09:00-19:00 Off peak 216 1st April to 31st October, between 19:00-22:30, Winter (24h) and nights (22:30-05:00) Table 10: Combined demand and noise charges for departure movements resulting from the framework of charges in 2017/18 Noise Category Peak Base Off Peak Summer Winter Summer Summer Summer Night Night Chapter 3 1, , Chapter 4 1, Chapter 14 High Chapter 14 Base Chapter 14 Minus Table 11 shows the charges per noise category as a percentage relative to the Chapter 4 charges, illustrating the surcharges and discounts emerging from the new framework of charges. Noise charges for the night period (summer and winter) for the noisiest Chapter 3 aircraft commands a surcharge of 70% in summer and a surcharge of 100% in winter relative to Chapter 4 charge, while the Chapter 14 categories have discounts of July

39 28%, 35% and 42% in the summer night period for Chapter 14 High, Chapter 14 Base and Chapter 14 Minus respectively. The discounts in the winter night period range from 40% for Chapter 14 High and 60% for Chapter 14 Minus. At other periods, presented in the table, the surcharge varies from 4% to 15%, and the discounts vary from 2% to 9%. Table 11: Differential charging per noise category relative to Chapter 4 (departure movements) Noise category Peak Base Off-Peak Summer Winter Summer Summer Summer night night Chapter 3 104% 106% 115% 170% 200% Chapter 4 100% 100% 100% 100% 100% Chapter 14 High 98% 98% 94% 72% 60% Chapter 14 Base 98% 97% 92% 65% 50% Chapter 14 Minus 98% 97% 91% 58% 40% 3.50 According to GAL, in 2020/21, the proportion of movements served by Chapter 14 Minus is forecasted to be 40%, in contrast to the current 3%. This is based on assumptions made on passenger growth (of 2% per annum) outpacing movement growth (1% per annum). Under this scenario, in 2020/21, for Chapter 14 Minus, the day noise charge will increase by 25% and night noise charge will increase by 29%. We welcome these figures as a first step towards airports providing more information on forecast changes to environmental charges. Determination of noise category of aircraft 3.51 The methodology followed by Gatwick airport up until 2016/17 to determine the noise category of aircraft was as follows: Chapter 2: Aircraft which are either not certificated or fail to meet the noise certification standards of ICAO Annex 16 Chapter 3. High: Defined set of aircraft that meet the noise certification standards of ICAO Annex 16 Chapter 3 unless the operator can provide satisfactory noise certification data demonstrating that the aircraft noise performance is at least - 5 EPNdB (cumulative) below the ICAO Annex 16 Chapter 3 certification limits. July

40 Chapter 3 Base: Aircraft which meet the noise certification standards of ICAO Annex 16 Chapter 3 and are not classified as either Chapter 3 High or Chapter 3 Minus. Chapter 3 Minus: Aircraft which meet the Chapter 3 standard and, on both arrival and departure, have a Quota Count 17 (QC) of 0.25, 0.5 or 1, or are exempt from a QC rating. Chapter 4: Aircraft which were either put into service on or after 1 January 2006 and meet the noise certification standards of ICAO Annex 16 Chapter 4 or can demonstrate that they meet the noise certification standards of ICAO Annex 16 Chapter From the year 2017/18, GAL grouped all Chapter 3 and below aircraft into a single noise charging category (Chapter 3 and Below), with the Chapter 4 category remaining unchanged. The airport also introduced Chapter 14 High, Base and Minus in its framework of charges. These subcategories are each 3 EPNdB wide and based on the cumulative margin to Chapter 3 exceeding -17, -20 and -23 db respectively. Movement and QC limits during the night quota period 3.53 At Gatwick the number of movements in the night quota period is limited to 11,200 in the summer season and 3,250 in the winter season respectively (total of 14,450 movements). In addition to a limit on night time movements there is also a noise quota limit, limiting the total amount of noise based on a system of noise quota counts assigned to individual aircraft type variants. Table 12 and Table 13 present the movement and noise quota limits at Gatwick airport from 2006/07 to 2016/17, for summer and winter Figure 11 and Figure 12 illustrate the values in the tables. In the 2015 and 2016 summer seasons, the movement usage was 99.5% and 100.9% respectively (Table 12). During that period the noise quota used was 76.9% in the summer of 2015 and 79.2% in the summer of During the winter period the lower demand is reflected in a lower movement and 17 The Quota Count is a weighting attributed to the arrival or departure of a specified aircraft type by reference to its certificated noise performance, divided into 3 EPNdB bands. July

41 noise quota usage; in the 2016/17 winter, the movement usage was 62.2% of the limit while 59.9% of the noise quota limit was used (Table 13). Table 12: Movements and noise quota usage in the summer period at Gatwick Airport from 2007 to 2016 Movements Noise quota Usage Limit % Used Usage Limit % Used Summer ,173 11, % 5, , % Summer ,618 11, % 5, , % Summer ,099 11, % 4, , % Summer ,875 11, % 4, , % Summer ,859 11, % 4, , % Summer ,837 11, % 4, , % Summer ,998 11, % 4, , % Summer ,147 11, % 4, , % Summer ,149 11, % 4, , % Summer ,303 11, % 4, , % Figure 11: Movement and noise quota usage against the limits at Gatwick Airport in the summer night quota period between 2007 and 2016 July

42 Table 13: Movements and noise quota usage in the winter period at Gatwick Airport from 2006/07 to 2016/17 Movements Noise quota Usage Limit % Used Usage Limit % Used Winter 2006/07 2,734 3, % 1, , % Winter 2007/08 2,929 3, % 1, , % Winter 2008/09 2,145 3, % 1, , % Winter 2009/10 2,199 3, % 1, , % Winter 2010/11 2,160 3, % 1, , % Winter 2011/12 1,411 3, % , % Winter 2012/13 1,603 3, % 1, , % Winter 2013/14 1,510 3, % , % Winter 2014/15 1,756 3, % , % Winter 2015/16 1,872 3, % , % Winter 2016/17 2,022 3, % 1, , % Figure 12: Movement and noise quota usage against the limits at Gatwick Airport in the winter night quota period between 2006/07 and 2016/17 Fleet analysis by noise category 3.55 Based on information provided by Gatwick airport, the aircraft mix by noise category for 2010/11 and 2015/16 18 can be seen in Figure 13, which shows that 97% of operations were served by Chapter 4 aircraft and 3% by Chapter 3 Minus aircraft in 2015/16. The number of Chapter 3 aircraft operating has decreased by 22% in 2015/16 relative to 2010/ Source: Gatwick Airport Finance Department. July July

43 Figure 13: Gatwick aircraft mix, % operations by noise category 100% 90% 80% 70% 60% 50% 40% 30% 20% 10% 0% Chapter 3 Base Chapter 3 Minus Chapter 4 Noise Category 2010/ /16 Source: Gatwick Airport Limited 3.56 Under the current or previous noise categorisation, it is not possible to verify levels of Chapter 4 High and Chapter 4 Base operations as GAL has not sub-divided the Chapter 4 standard into separate noise categories. It has not been possible, with the information available on Gatwick s fleet, to determine the aircraft mix by noise category. In the absence of a global database, noise certification levels for aircraft operating at Gatwick airport have only been available to us for aircraft registered in the UK (UK registered). Information given below in regard to aircraft movements per noise category has been obtained from the Gatwick operational database (Casper) 19 for arrival operations during the financial year (1 st April to 31 st March) In 2010/11, 26% of the aircraft fleet at Gatwick were UK registered (642 aircraft) accounting for 77% of total movements, while in 2015/16, 24% were UK registered (576 aircraft) accounting for 72% of total operations. This sample is assumed to be representative of the overall fleet at Gatwick airport for the purpose of this report Table 8 showed the charge for Chapter 3 aircraft is double the charge for Chapter 4 aircraft. However, according to operational data from Gatwick airport only 3% of operations are Chapter 3 or below, as shown in 19 The Gatwick Noise and Track Keeping (NTK) system July

44 Figure 13. Considering only UK registered aircraft, Figure 14 shows that 98% of aircraft movements were Chapter 4 or above in 2015, in contrast to 81% in 2010, even though the fleet was made up of 95% and 97% Chapter 4 aircraft or above in 2010/11 and 2015/16 respectively. In light of the small percentage of operations affected, the higher charge on Chapter 3 aircraft still present in Gatwick s framework of charges acts as an effective back stop. Figure 14: Gatwick Airport movements distribution by previous noise category for UK registered aircraft 70% 60% 50% 40% 30% 20% 2010/ /16 10% 0% Chapter 3 High Chapter 3 Base Chapter 4 High Noise Category Chapter 4 Base Chapter 4 Minus 3.59 The operations that occurred at Gatwick Airport in both 2010/11 and 2015/16, with the current noise categorisation, are illustrated in Figure 15. The current set of noise categories subdivide Chapter 4 into Chapter 4 High and Chapter 4 Base with 10% and 20% share of operations respectively. Sixty-seven percent (67%) of movements at Gatwick meet the new Chapter 14 standard with 46% falling in the Chapter 14 High category, 18% in the Chapter 14 Base category and 3% in the Chapter 14 Minus category (for UK registered aircraft). July

45 Figure 15: Gatwick Airport movements distribution (%) by current noise category for UK registered aircraft 50% 45% 40% 35% 30% 25% 20% 15% 2010/ /16 10% 5% 0% Chapter 3 Chapter 4 High Chapter 4 Base Chapter 14 High Noise Categories Chapter 14 Base Chapter 14 Minus Discussion 3.60 There have been significant changes in the framework of charges at Gatwick airport since the publication of CAP As recommended in CAP 1119, demand charges have been separated from environmental charges. GAL also introduced new noise charging bands for quieter aircraft that have lower costs for the best performing aircraft and higher costs for poorer performing ones. We welcome these changes to the framework of charges We further welcome that GAL has separated noise landing charges for landing and take-off and that these are based on the actual time of operation In regard to categorisation of aircraft, the division of noise categories for charging purposes does not reflect the present mix of aircraft at Gatwick. Most operations are served by Chapter 4 aircraft. Just 2% of operations are attributed to Chapter 3 Minus aircraft (the quietest aircraft that meets the ICAO Chapter 3 Base standard) GAL accepts that the structure of aircraft noise charges has remained unchanged for a number of years and no longer reflects the most recent July

46 developments in airframe and engine technology 15. Indeed, it seems disproportionate to divide Chapter 3 into two subcategories when no operations were served by Chapter 3 Base aircraft in 2015/16, and residual operations were attributed to Chapter 3 Base in 2010/11 (Figure 13). On the other hand, the Chapter 4 category is not subdivided despite accounting for 75% and 97% of operations in 2010/11 and 2015/16 respectively. This appears inconsistent CAP 1119 observed that there was insufficient differentiation between the aircraft with higher cumulative margins that make up the vast majority of operations. The current fleet has 10% of operations served by Chapter 4 High, and 20% served by Chapter 4 Base. The previous categorisation chosen by Gatwick with a single Chapter 4 category may have been unhelpful, as it masks the next noise category to be targeted, the Chapter 4 High By not subdividing its Chapter 4 charging band, Gatwick s charging system has a 7dB wide band (from -10dB to -17dB relative to the Chapter 3 limits). Whilst this may encourage operators, where they can, to select aircraft with margins in excess of -17dB, it does nothing to incentive operators to use quieter aircraft within the Chapter 4 charging band CAP 1119 recommended that for consistency and purposes of harmonising airport charges schemes, Chapter 4 High and Chapter 4 Base should be disaggregated noise categories so Chapter 4 High can be targeted with landing charges aligned with its own noise ratio As mentioned in paragraph 3.44, GAL has introduced a financial mechanism to Airbus A320 aircraft which have not carried out the FOPP modification by levying such aircraft with the highest charge in the framework of noise charges, namely Chapter 3 in the night period. This charge will be applied from the start of 2018, which has given airlines over a year to plan and modify their A320 aircraft in order avoid the charge. We welcome such initiatives by airports to address noise issues, and note that there is already evidence that the levy is encouraging adoption of the FOPP modification, reducing approach noise. July

47 3.69 As with Heathrow airport, we believe that a forecast setting out the likely rate of increase in charges would show the continued efforts invested in moving Gatwick airport s fleet to quieter aircraft. It would need to be developed in consultation with airport users, assessing their potential ability to reasonably introduce best in class aircraft from their forecast fleet The numbers of night movements in the Night Quota Period are set by government. Although Gatwick exceeded the summer season movement limit by 1% in Summer 2016, it offset this against unused movement quota in the winter period under the Night Quota System rules permitting it to trade up to 10% of movements from one season to another A noise charge has been introduced for night flights in winter, where there was previously no charge. GAL has decided also to recover 50% of noise charges from the day period and 50% from the night period, despite the latter accounting for only 5% of total flights. Consequently, the noise charges during the night period are adjusted accordingly, resulting in them being more than 12 times the day charge. We welcome these changes However, because the demand charges are much lower in the night period, some aircraft incur a lower overall (noise + demand) charge at night than during the day, despite the night noise charge being 12 times the day noise charge. This leads to a situation where an aircraft may be charged less to operate at night, than during the daytime which seems counterintuitive and risks incentivising airlines to operate night movements. We would like to see GAL plan to set night charges in subsequent years which disincentivise night operations, and to set these out in the forecast recommended in paragraph In addition, relative to the previous year, charges during the summer night period for 2017/18 are lower for the aircraft which are reallocated from the Chapter 4 category to the recently introduced Chapter 14 categories. Those that remain in Chapter 4 incur a higher charge than the previous year and thus the revised charging scheme now incentivises a shift from Chapter 4 to Chapter 14 during both day and night. As 67% of the fleet at July

48 Gatwick already meet the Chapter 14 standard, they benefit from this change by incurring lower noise charges without changing noise exposure. Stansted Airport Determination of noise category of aircraft 3.74 The CAA understands that noise environmental charges at Stansted are set based on the cumulative margin to the Chapter 3 limits, rather than the ICAO noise Chapter to which the aircraft is certified. It also includes a subcategory called Chapter 3 Minus which is based on QC values (QC/1 or quieter on both arrival and departure), and a Chapter 4 category for aircraft that meet the noise certification standards of ICAO Annex 16 Chaper 4. However, it is unclear from the description given in the Conditions of Use 2017/18 whether Chapter 3 and Chapter 4 aircraft with the same cumulative margin would be levied the same noise charge. Landing charges overview 3.75 This section looks at the current status of landing charges at Stansted Airport. In addition, a summary of the charging system at Stansted is presented in Table There has been a 3% increase in landing charges at Stansted Airport between 2014/15 and 2016/17 across noise categories and Maximum Total Weights 20 ; and a 2% increase in 2017/18 compared to 2016/ The noise categories that command the lowest charge (Chapter 3 Minus and Chapter 4) apply to aircraft with QC values (in both arrivals and departures) of 0.25, 0.5, 1 or that are exempt or entered into service from At peak times (1 st April to 31 st October), for aircraft of more than 55 tonnes, the charge is 164% of that applying to aircraft of more than According to Stansted Airport s Conditions of Use for 2017/18, Maximum Total Weight refers to Maximum Total Weight Authorised, which means the maximum total weight of the aircraft and its contents at which the aircraft may take-off anywhere in the world in the most favourable circumstances in accordance with the Certificate of Airworthiness in force in respect of the aircraft. July

49 Landing Charge (GBP) CAP 1576 tonnes and less than 55 tonnes. For aircraft heavier than 250 tonnes, the charge is 282% of that for aircraft of more than 16 tonnes and less than 55 tonnes, across all noise categories. In Off-Peak times (1 st November to 31 st March), landing charges are 26% lower than the Peak counterpart. It is worth noting that the framework of charges at Stansted airport does not discern between day and night periods Figure 16 shows the evolution of charges from 2014/15 to 2017/18 for an aircraft with Maximum Total Weight between 16 tonnes and 55 tonnes by noise category. Although absolute values have increased slightly (see Figure 16), the relationship between charges of different categories, total weight or time of day have remained the same over the period. Figure 16: Stansted Airport landing charges, peak time for aircraft between tonnes, Chapter 2 Chapter 3 High Chapter 3 Base Chapter 3 Minus Chapter / / / / Noise categories Chapter 3 Minus and Chapter 4 are grouped together and therefore levy the same tariff, which is 10% lower than that for Chapter 3 Base aircraft. Chapter 3 High aircraft are levied 50% more than Chapter 3 Base (see Figure 17). July

50 Figure 17: Stansted Airport landing charge per noise category relative to Chapter 3 base Chapter 4 90% Chapter 3 Minus 90% Chapter 3 Base 100% Chapter 3 High 150% Chapter 2 300% 0% 50% 100% 150% 200% 250% 300% 350% Movement and QC limits during the night quota period 3.80 At Stansted the movement limit stands at 7,000 in the summer and 5,000 in the winter night quota period (total of 12,000 movements). Table 14 and Table 15 illustrate movements and quota used over time. In the summer of 2016, the movement usage was at 105.3% and the noise quota usage was at 99.6% (Table 14). During the winter period of 2016/17 the lower demand is reflected by a lower movement and noise quota usage of 65.8% and 70.9% respectively (Table 15). Table 14: Movements and noise quota usage in the summer period at Stansted Airport from 2007 to 2016 Movements Noise quota Usage Limit % Used Usage Limit % Used Summer ,307 7, % 4, , % Summer ,498 7, % 3, , % Summer ,979 7, % 3, , % Summer ,081 7, % 3, , % Summer ,004 7, % 3, , % Summer ,837 7, % 3, , % Summer ,614 7, % 3, , % Summer ,747 7, % 4, , % Summer ,347 7, % 4, , % Summer ,370 7, % 4, , % July

51 Figure 18: Movement and noise quota usage against the limits at Stansted Airport in the summer night quota period between 2007 and 2016 Table 15: Movements and noise quota usage in the winter period at Stansted Airport from 2006/07 to 2016/17 Movements Noise quota Usage Limit % Used Usage Limit % Used Winter 2006/07 3,751 5, % 2, , % Winter 2007/08 3,612 5, % 2, , % Winter 2008/09 3,196 5, % 2, , % Winter 2009/10 3,426 5, % 2, , % Winter 2010/11 2,595 5, % 1, , % Winter 2011/12 2,298 5, % 1, , % Winter 2012/13 2,876 5, % 2, , % Winter 2013/14 2,778 5, % 2, , % Winter 2014/15 2,840 5, % 2, , % Winter 2015/16 3,105 5, % 2, , % Winter 2016/17 3,289 5, % 2, , % Figure 19: Movement and noise quota usage against the limits at Stansted Airport in the winter night quota period between 2006/07 and 2016/17 July

52 Fleet by noise category: analysis 3.81 In 2015/16, there were 269 airlines operating at Stansted of which 17 accounted for 94% of operations. The main operators at Stansted are Ryanair (with 68% of total operations) and easyjet (with 11% of total operations) Ryanair used a fleet of 354 aircraft, and all but nine were Boeing , the majority of them are Chapter 4 High. In September 2014, Ryanair placed an order to purchase 200 Boeing 737 MAX 200 aircraft, with first deliveries due in These aircraft will meet the new Chapter 14 standard easyjet, likewise, is expecting delivery of 100 A320neo aircraft (meeting Chapter 14 Minus criteria) between 2017 and , having replaced part of its fleet already with current generation A320s which already meet the Chapter 14 standard (over 33% of current generation A320 aircraft meet Chapter 14 standard) The CAA only holds noise certification data for UK registered aircraft. Ryanair s fleet are not UK registered but the noise category of the majority of its Boeing aircraft are Chapter 4 High. Ryanair s fleet and the UK registered aircraft operating at Stansted accounted for 88% of operations in 2015 and 82% in The percentage of operations per noise category for both the previous and current categories are presented in Figure 20 and Figure 21, respectively. This shows that operations at Stansted Airport have been mostly served by Chapter 4 High aircraft in both 2010 and The fleet mix at Stansted airport in 2015 compared to 2010 shows an increase of movements served by higher noise categories (i.e. noisier aircraft) and a decrease of movements served by lower noise categories (quieter aircraft). This is unsurprising, since the proportion of total movements by the Boeing have increased at Stansted over the same period. 21 Ryanair website Accessed July easyjet website: Accessed July 2017 July

53 3.85 Chapter 4 Base in the previous noise category system represents aircraft with a cumulative margin relative to ICAO Chapter 3 of between -15 and -20 EPNdB. In the current noise category classification, Chapter 4 Base represents aircraft with a cumulative margin between -15 and -17 EPNdB. The narrowing of the range of Chapter 4 Base explains the reduction of the Chapter 4 Base percentage contribution as presented with the newly adopted noise categorisation (Figure 21) relative to the previous noise categorisation (Figure 20). Figure 20: Stansted Airport percentage of operations by previous set of noise categories for the years 2010/11 and 2015/16 90% 80% 70% 60% 50% 40% 30% 2010/ /16 20% 10% 0% Chapter 3 Base Chapter 4 High Chapter 4 Base Chapter 4 Minus Noise Categories Figure 21: Stansted Airport percentage of operations by current noise categories for the years 2010/11 and 2015/16 90% 80% 70% 60% 50% 40% 30% 2010/ /16 20% 10% 0% Chapter 3 Chapter 4 High Chapter 4 Base Chapter 14 High Noise Categories Chapter 14 Base Chapter 14 Minus July

54 Discussion 3.86 There have not been significant changes in the framework of charges at Stansted airport since publication of CAP Of the three designated airports, Stansted has shown the lowest uptake of the recommendations laid out in CAP Stansted airport is the only designated airport that still has not set a night period in its charging framework. The Aviation Policy Framework, 23 which sets out Government objectives and policy in regard to aviation, recognises that the impact and costs on local communities are higher from aircraft noise at night than it is during the day, but also that it is neither reasonable nor realistic for such actions to impose unlimited costs on industry. Instead, measures to address noise impacts should be proportionate to the extent of the noise problem and numbers of people affected In line with Government objectives, CAP 1119 recommended that Noise charges for operations occurring at night should be greater than those that occur during the day. Since the publication of CAP 1119 there have not been changes at Stansted airport aimed at addressing a differentiation of charges between day and night periods. As a result, the current structure of charges at Stansted airport does not discern between day and night operations, a differentiation that we believe it is necessary in order to a) be able to target night noise at Stansted, b) show harmonisation with practices at other airports, and c) account for the higher impact that night noise has in relation to day noise In regard to landing charges per noise category, Chapter 2 and Chapter 3 High noise categories have relatively high landing charges (Figure 16) although no movements were attributed to either noise category in 2015 (based on analysis of movements by UK registered aircraft and those operated by Ryanair). As with Heathrow and Gatwick airports, the higher 23 Aviation Policy Framework, Department for Transport, March 2013 July

55 charges for these noise categories are effectively a back stop rather than encouraging a shift to best in class As a consequence, a significant majority of Stansted operations fall in two noise charging categories. Differential charging is intended to encourage operators to bring best in class aircraft by levying above a standard rate for noisier aircraft and below a standard rate for quieter aircraft. However, the noise categories in Stansted s framework of charges appear to be too broad for that purpose. CAP 1119, recommendation b) states that Noise charging categories should be of equal width, typically 5 EPNdB, or narrower, to ensure adequate differentiation of noise performance (see Table 17) Under the present regime, the Chapter 4 category is not disaggregated into its subcategories, Chapter 4 High and Chapter 4 Base. In fact, it is grouped, for billing purposes, with Chapter 3 Minus. We recommend Stansted Airport disaggregates Chapter 4 aircraft into subcategories, namely Chapter 4 High, Chapter 4 Base and the Chapter 14 standard subcategories in line with CAP 1119 recommendations a) to c) (Table 17). This follows our recommendation in regard to harmonisation in charges schemes at UK airports as stated in CAP 1119 recommendation g) As illustrated in Figure 20 and Figure 21, the next noise category to be incentivised for phasing out is the Chapter 4 High category. However, it is not seen as a straight forward action, since the main operator uses a single Chapter 4 High type of aircraft, which in the event of increasing landing fees differentials may result in an unreasonable operational restriction given the difficulty the operator would have in responding to it On the other hand, the new Boeing 737 MAX 200 aircraft orders that Ryanair has placed, with deliveries starting in 2019, in combination with easyjet s forthcoming A320neos, are arguably expected to increase significantly the proportion of quieter aircraft operations at Stansted. Despite this positive outlook, it is uncertain how significant the changes in the fleet mix will be. July

56 3.94 In summary, we believe that a forecast setting out the likely rate of increase in charges for Chapter 4 aircraft would help to drive further improvements in environmental impacts at Stansted. It would need to be developed in consultation with airport users, assessing the potential ability of operators to reasonably bring best in class aircraft from their forecasted fleet. Current framework of noise-related charges at nondesignated airports 3.95 This section gives details of the current framework of noise related charges at the three non-designated study airports. In addition, a summary of charging systems at the study airports is presented in Table 3. Manchester Airport 3.96 Manchester Airport levies runway charges on departures, based on Maximum Take-Off Weight (MTOW) authorised, QC category and time of day and year The runway charges levied to passenger aircraft are shown in Table 16. Cargo aircraft are levied 6.62 per tonne in standard period and 3.43 per tonne in off-peak period (-48%). The Off-peak period for cargo operations is from , and , which is a different period from that applied to passenger aircraft. July

57 Table 16: Manchester airport departure runway charges for passenger aircraft in 2017/18 Applicable time of day Summer Standard Summer Off- Peak Winter Standard Same as Summer Standard Winter Off- Peak Same as Summer Off-Peak <25 tonnes 6.67/tonne 6.67/tonne 6.14/tonne 6.14/tonne MTOW Authorised tonnes >120 tonnes 8.20/tonne 6.67/tonne 7.56/tonne 6.14/tonne 8.20/tonne 6.67/tonne 7.65/tonne 6.14/tonne (120T) + (120T) /tonne 4.11/tonne (thereafter) (thereafter) 3.98 The framework of charges at Manchester Airport does not differentiate by noise category. The only charges relating to noise are: Only Chapter 3, Chapter 4 or Chapter 14 aircraft are allowed to be scheduled to land or take off in the period from Noisier aircraft that are permitted to land or take off will incur a 70% surcharge. East Midlands Airport Passenger aircraft 3.99 East Midlands Airport levies a runway charge of 10.41/tonne on departures for all passenger aircraft. A surcharge of 25% is applicable in the night period between , for aircraft that are rated QC4 or above Between , QC8 and QC16 aircraft are only allowed to operate in exceptional circumstances (such as delays for technical reasons). When permitted, operations will incur a penalty of 5,000 for QC8 aircraft and 10,000 for QC16 aircraft. July

58 Cargo aircraft Charges for cargo aircraft are levied at 0.94 per tonne (base charge) for both arrivals and departures. In the shoulder periods (between and ), there is an additional charge of 1.90 per tonne on arrivals and departures (200% surcharge relative to base charge) In the night quota period, , and in addition to the runway charge, cargo aircraft is charged depending on their QC category: 2.86 per tonne for QC<1, 3.18 for QC1, 3.32 for QC2 and 3.50 for QC4. Relative to the base charge, the night surcharges range from 305% for aircraft rated at QC<1 to 374% for QC4 aircraft. Between , QC8 and QC16 aircraft are only allowed to operate in exceptional circumstances; when permitted, these operations will incur a penalty of 5,000 for QC8 aircraft and 10,000 for QC16 aircraft. Birmingham Airport Passenger aircraft Charges on passenger aircraft are levied based on authorised MTOW at per tonne on departure. There is no noise element to this charge. Cargo aircraft For cargo operations of aircraft below 30 tonnes, departures are charged at the same rate as passenger aircraft. For heavier aircraft the charges apply to both arrivals and departures, and depend on the time of day. Between (day period) a charge of 1.69 per tonne is levied; in the shoulder period (between and ) the charge is 3.37 per tonne (100% surcharge relative to day period rate); and for the night period, , the charge is 5.05 per tonne (200% surcharge relative to the day period rate). Non-designated airports: summary The three non-designated airports do apply some differentiation of charges depending on the noisiness of the aircraft, whether it is applied according to QC categories as it is in Birmingham and East Midlands, or July

59 according to QC categories and ICAO noise standards as is the case for Manchester Airport. However, some airports, as Manchester airport in this report, charge more for passenger aircraft than cargo aircraft, irrespective of the noise certification levels of the aircraft. This may reflect airport business decisions, however, our recommendation in CAP 1119 was, and continues to be, that noise and business related charges (e.g. demand or operation type) should be separated and that noise charges should be linked to certificated noise performance The only noise-related charge differential applied at Manchester Airport is the surcharge of 70% applied during the night period to aircraft that fail to meet the Chapter 3 standard (Chapter 2 aircraft with an MTOW greater than 34 tonnes have been banned from the EU since 2002, and only under specific circumstances are operations are granted. However those below 34 tonnes may continue to operate) At Birmingham Airport, there is no differentiation of charges by noise category, but, in regard to night noise, cargo operations of aircraft of more than 30 tonnes command a 200% surcharge during the night period relative to the day charge At East Midlands Airport, passenger aircraft are levied a 25% surcharge during the night for the noisiest aircraft, rated QC4 and above. Cargo operations during the shoulder period command a 200% surcharge (relative to daytime). During the night, a differential charge is applied in addition to standard runway charges depending on the QC rating of the aircraft (from 2.86 per tonne for QC<1 to 3.50 per tonne for QC4, applying equally to arrivals as well as departures) Overall, the charging schemes at the three non-designated airports are quite different to each other and to those at the designated airports. The non-designated airports have not yet made changes to their charging schemes following the recommendations made in CAP July

60 Emissions-related charges Chapter 4 Emissions-related charges 4.1 The EU, through The Air Quality Framework Directive on Ambient Air Quality, has placed a requirement on Member States to achieve prescribed health based air quality limits which are legally binding and to be met by the UK government. In regard to NOx emissions the EU/UK annual average limit value is 40µg/m 3 and 200 µg/m 3 is the peak limit (measured as a 1 hour mean which is not to be exceeded more than 18 times in a calendar year). 4.2 In addition, under the Environment Act 1995, local authorities have a statutory duty to assess air quality in their area. Concern or likelihood of breaches of limits in a particular locality may lead the local authority to declare an Air Quality Management Area (AQMA). 4.3 Consequently, local air quality is part of the agenda for the sustainable development of airport activities as action must be taken where necessary to avoid breaching the limits. The three designated airports produce annual updates to their air quality strategy objectives. 4.4 Heathrow and Gatwick airports levy emission charges as they are experiencing, or are likely to experience, a local air quality problem. Such concerns are not present at the other study airports, and consequently they do not levy an emissions charge. Heathrow Airport 4.5 Heathrow Airport is surrounded by main roads as well as an industrial estate that contributes significantly to local air quality pollutant emissions. Consequently, the allocation of emissions to their sources is not straightforward, however Heathrow Airport has reported that the contribution of the airport to NOx pollutant levels is 30% at the boundary of airport and decreasing fast beyond the boundaries. Three air quality July

61 Emissions-related charges monitoring sites have consistently recorded breaches of the annual average limit. 24 One of the sites is within the airport boundary and not accessible to the public (LHR2), another is at a junction of the M4 motorway (Hillingdon at 2.0 km from closest runway point), and the third is in Hayes (at around 2.6 km from closest runway point) see Figure 22. Aircraft activity has a limited effect at the latter two monitoring sites, as non-aviation stationary sources and road traffic are the main contributors to pollutant levels at these locations. Pollutant levels in residential areas close to the boundaries of the airport have not breached EU/UK limits. Nonetheless, the four local authorities surrounding Heathrow have all declared AQMAs for NO2 (NO2 and NO are nitrogen oxides which, together, are generally referred to as NOx when relating to air pollution). Heathrow Airport is working with these local authorities to monitor and improve air quality. Figure 22: Map of Heathrow Airport and surroundings 24 Q briefing and end of year summary. Air Quality at Heathrow Airport. (accessed July 2017) July